ML19326C538
| ML19326C538 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 06/13/1978 |
| From: | David Williams ARKANSAS POWER & LIGHT CO. |
| To: | Reid R, Stolz J Office of Nuclear Reactor Regulation |
| References | |
| 1-068-6, 1-68-6, NUDOCS 8004230657 | |
| Download: ML19326C538 (2) | |
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O&(r 21l+7T REGULATORY INFORMATION DISTRIBUTION SYSTEM (RIDS DISTRIBUTION FOR INCOMING MATERIAL 50-7 _/368 REC: REID R W ORG: WILLIAMS D H DOCDATE: 06/13/78 NRC AR PWR & LIGHT DATE RCVD: 06/23/78 DOCTYPE: LETTER NOTARIZED: NO
SUBJECT:
COPIES RECEIVED LTR 4 ENCL 40 FURNISHING INFO CONCERNING SUBJECT FACILITY"S FIRE BRIGADE SIZE...W/ATT VIDEOTAPE FIRE PROTECTION TRAINING PROGRAM.
AND BASIC FIRE TRAINING FOR FBST.
PLANT NAME: ARKANSAS - UNIT 1 REVIEWER INITI AL:
XJM ARKANSAS 1 - UNIT 2 DISTRIBUTER INITI AL:
ooocoo*********** DISTRIBUTION OF THIS MATERIAL IS AS FOLLOWS ******************
PSAR/FSAR AMDTS AND RELATED CORESPONDENCE (DISTRIBUTION CODE BOO 1)
FOR ACTION:
ASST DIR B GRIMES **LTR ONLY DR CHIEF ORB #4 BC**LTR ONLY PROJ MGR VISSING**W/ ENCL LIC ASST ORB #4 LA**LTR ONLY' INTERNAL:
- W/ ENCL NRC PDR**W/ ENCL I !
x=W/2 ENCL DELD**LTR ONLY OPERATOR LIC BR**W/ ENCL EMERGENCY PLAN BR**W/ ENCL QAB**W/ ENCL DIRECTOR NRR**LTR ONLY MIPC**LTR ONLY AD FOR ENG**LTR ONLY MECH ENG BR**W/ ENCL STRUCTURAL ENG BR**W/ ENCL MATERIAL ENG BR**W/2 ENCL AD FOR REAC SFTY**LTR ONLY REACTOR SYSTEMS BR**W/ ENCL ANALYSIS BR**W/ ENCL CORE PERFORMANCE BR**W/ ENCL AD FOR PLANT SYSTEMS **LTR ONLY AUXILIARY SYS BR**W/ ENCL CONTAINMENT SYSTEMS **W/ ENCL I L C SYSTEMS BR**W/ ENCL POWER OYS BR**W/ ENCL AD FOR SITE TECH **W/4 ENCL AD FOR SITE ANLYS**LTR ONLY ACCIDENT ANALYSIS **W/ ENCL EFFLUENT TREAT SYS**W/ ENCL RAD ASSESSMENT BR**W/ ENCL KIRKWOOD**W/ ENCL GEOSCIENCES BR**W/ ENCL EXTERNAL:
LPDR'S
[f{c h 3 {,l RUSSELLVILLE, AR**W/ ENCL i
i TIC **W/ ENCL NSIC**W/ ENCL 1
ACRS CAT B**W/16 ENCL i
i ISTRIBUTION:
LTR 57 ENCL 47 IZE: 4P+1P+1P CONTROL NBRW1'UlDOSS---
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THE END 1
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ARKANSAS POWER & LIGHT COMPANY POST OFFICE BOX 551 LITTLE ROCK, ARKANSAS 72203 (501) 371 1000 June 13,1978
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2-068-14 L.l y
Director of Nuclear Reactor Regulation ATTN: Mr. R.W. Reid, Chief Operating Reactor Branch #2 Mr. J. F. Stolz, Chief Light Water Reactors Branch #1 U. S. Nuclear Regulatory Commission Washington, D. C. 20555
Subject:
Arkansas Power & Light Company Arkansas Nuclear One-Units 1 & 2 Docket Nos. 50-313, 50-368 License No. DPR-53 Fire Brigade Size (File:
1510 2040 2-1510 2-2040 Gentlemen:
During the appeals meeting Friday, June 9, 1978, we discussed, with the Staff, our problems in complying with the Staff Position of a five (5) man Fire Brigade. We also stated, and reiterate here for emphasis, that several utilities (as many as fourteen (14) of which we are directly aware) have severe problems with the position and have previously met to develop a united position against the requirement.
AP&L has and will continue to participate in that group effort.
Following our presentation, and subsequent discussion, it is our under-standing that the Staff agreed that a three (3) man Fire Brigade with two (2) support personnel with a lesser degree of fire fighting training than that required for the Fire Brigade (FB) would be adequate to combat those fires that could occur in a nuclear posar plant.
We also under-stand that these additional two (2) support i;ersons would not have to be operations personnel but could be from any other plant personnel inclusive of security personnel.
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1-068-6 2-068-14 Mr. R. W. Reid Mr. J. F. Stolz June 13, 1978 We have a video tape fire protection training program used as part of the Fire Brigade Initial Classroom Training Program.
An outline of this program is attached as Attachment 1.
As a matter of company policy, we feel it prudent to train the two (2) additional support personnel (Fire Brigade Support Team, FBST) with this program to assure their personal safety. The program presents general, basic fire protection /
fighting information augmented by information on plant specific items.
This course will give the FBST good basics in fire protection / fighting.
We do not believe the FBST should be trained in strategy (eg., prefire plans,etc.).
We believe they should be trained how to use the equipment but only under the direct supervision of a fully trained Fire Brigade Member (FBM). lists the significant areas of training applicable to the FB, and denotes those areas where training of the FBST is equal or different.
Those areas of equal training do not deserve further discussion.
Item 5.
As with the FB, no special training is given in the use of lighting as all systems are automatic with the exception of the flashlights provided.
Neither the FB or FBST should require training in the use of flashlights.
Item 7.
The FBST will be instructed in the operation of our portable smoke removal equipment. A FBM will direct positioning of that equip-ment at the scene of a fire based on his training in strategy of fighting a fire.
Item 8.
The FBST will be introduced to the installed automatic systeis as to location and method of actuation.
They will be instructed to actua;e one of those systems only under direct order from a FBM who will make the decision for the necessity of the actuation of that system based on his 3
training in strategy of fighting fires.
4 Item 9.
The FBST will be trained only in the basics of fire fighting strategy such as how to approach a fire, what type extinguisher to use, etc. He will have sufficient training to participate in a fire fighting activity but only under the direct supervision of a FBM.
Item 12. Since the primary function of cne Fe?T will be a support role to the FB (eg. changing air bottles, communication, providing additional equipment. etc.) as opposed to actually fighting fires, we do not believe practice in fighting fires is necessary.
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1-068-6 2-068-14 Mr. R. W. Reid Mr. J. F. Stolz June 13, 1978 The level of training, as outlined here, for the FBST as opposed to the-FB is more than adequate to assure proper participation of the FBST and represent a substantially reduced financial burden imposed if full train-ing were required.
We wish to reiterate our position that we feel a three (3) man fire brigade is more than adequate to provide a fourth level of fire pro-tection at Arkansas Nuclear One. We will, however, agree to a three (3) man Fire Brigade with a two (2) man Fire Brigade Support Team trained as outlined above. We will agree to such only as an effort to expedite licensing and wish to make quite clear that such agree-ment is made without prejudice to future potential rulemaking pro-ceedings on this topic.
We must take exception to statements made by the Staff in regard to the validity of our Fire Hazards Analysis (FHA).
Our FHA was per-fonned on a circuit by circuit basis, evaluating the function and affect of loss of each circuit.
The staff applied much pressure and expressed a great deal of dismay for the length of time we took in completing our FHA.
Since the Staff indicated in our June 9, meeting they believe several years would be necessary to perfonn the type of analysis we did, we believe completion of such an analysis within a 14 month period to be conynendable.
We can see no use that has been made of our Fire Hazards Analysis in the Staff's review.
Our FHA shows clearly no need for detection (except in a few areas so designated) or manual fire fighting for protection of th'e public health and safety.
of the FHA on the basis of interchannel, cross system electrical inter-Comme action are not applicable.
Breaker settings are determined to specifically preclude this problem and perioidically checked to assure they are maintained.
Mechanisms are already in effect to assure that every design change including conduit routings are reviewed for their effect on the FHA.
An adequate review and acceptance of our FHA by the staff will make the FHA a valuable document and relieve us of most of the staff's required design changes in addition to making the fire brigade size question rather moot.
Lack of this acceptance makes the FHA (and the accompanying several man-year investment and critical time impact on AN0-2 licensing) a useless document.
As a result we must state our intention to neither establish i
or maintain the validity of our Fire Hazard Analysis nor to consider it a basis for any commitments.
We feel confident that this situation is but another unfortunate result of the situation the staff has be.en put in (requiring too much infonnation with too little time to preparc and review),
requiring their poorly considered and hasty deveiopment of positions on fire protection.
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Mr. R. W. Reid-Mr. J. F. Stolz June 13, 1978 We request your concurrence with the Fire Brigade Support Team Program described above.
Very truly yours,
.L A Daniel H. Williams Manager, Licensing DHW/JTE/ew Attachments I
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ATTACHMENT I Videotape Fire Protection Training Program I.-
Chemistry of fire and fire triangle
'II.
Fire types / classes A, B, C, D III.
Various fire extinguishing agents (water, foam, CO, Halon, dry chemical) 2 A.
When to use B.
How to apply C.
How to operate extinguishers and use fire hoses.
IV.
Fire prevention, datection, personnel safety equipment V.
Fire suppression - with special emphasis on A.
Oil and gas fires - includes basic strategy / approach B.
Electrical fires - includes basic strategy / approach VI.
Limiting fire damage VII.
Fire related problems in nuclear plants A.
Contamination / Radiation 8.
Security VIII.
Duties of Fire Brigade IX.
Coordination with outside agencies.
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ATTACHMENT II Basic Fire Training For FBST Item Degree of Training 1.
Hose Reels
- same as required for FB 2.
Portable Extinguishers
- same as required for FB 3.
Air Masks **
same as required for FB 4.
Communicction***
same as required for FB 5.
Lights none 6.
Other Equipment
- same as required for FB (Clothing, etc. )
7.
Portable Smoke Removal Equipment **
less than required for FB 8.
Installed Plant Fire Protection Systems **
less than required for FB 9.
Fire Fighting Strategies
- 1ess than required for FB
- 10. Electrical and other hazarde*
same as required for FB
- 11. Rescue **
same as required for FB
- 12. Practice Fires none
- 13. Team Drills same as required for FB U:
(*) Covered by Videotape Fire Protection Training Program
(**) Govered by supplemental classroom training
(***) Covered by general plant indoctrination.
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